Open Data Policy: IATI exclusions

Save the Children Nederland (SCNL) waardeert het concept van Open Data en hecht veel waarde aan transparantie en verantwoording. Save the Children Nederland is van mening dat door onze projectinformatie beschikbaar te stellen, we onze verantwoordelijkheid tegenover kinderen, gezinnen, gemeenschappen, de partners waarmee we werken, onze donateurs, andere supporters van onze activiteiten en het grote publiek versterken.

Save The Children Nederland is bovendien van mening dat door ons werk te publiceren, ontwikkelingssamenwerking effectiever kan worden door samenwerkingen, synergieën, netwerken en minder duplicatie. Daarom heeft SCNL besloten om programmagegevens te publiceren, in overeenstemming met de International Aid Transparency Initiative (IATI) -standaard.

Hieronder vindt u in het Engels ons volledige beleid omtrent de transparante en betrouwbare organisatie.

1. Introduction

Save the Children Netherlands (SCNL) values the concept of Open Data and is committed to transparency and accountability. Save the Children Netherlands believes that by making our project information available, we enhance our accountability to children, families, communities, the partners we work with, our donors, other supporters of our activities as well as the general public. Additionally, Save the Children Netherlands believes that by publishing about our work, development cooperation can be made more effective through collaborations, synergies, networks and reduced duplication. Therefore, SCNL decided to publish programme data, compliant with the International Aid Transparency Initiative (IATI) standard.

Save the Children fights for children’s rights and delivers life-changing projects to help children reach their full potential, wherever they are. Save the Children works in some of the most complex, insecure and fast-moving environments in the world and the safety and security of our staff and those of our partners is paramount. When a programme is marked for publication to IATI, we work on the principle that project information is published according to the IATI standard, unless it may compromise our ability to deliver life-saving projects for children and a clear reason is provided in accordance with our Exclusion Policy. This Exclusion Policy outlines the criteria to determine what information to exclude from being published.

Save the Children Netherlands started publishing its programme data in 2016 on a limited number of projects. In general, the decision to publish programmes will be determined in collaboration with relevant stakeholders at project inception. It is foreseen that the number of projects to be published through the IATI registry will gradually increase.

2. IATI publication overview

The International Aid Transparency Initiative (IATI) is a voluntary multi-stakeholder initiative that seeks to increase the transparency of development cooperation and consequently improve its effectiveness. At the center of IATI is a data standard, which provides a technical publishing framework allowing data from different publishers to be accessed and compared. A growing number of governments, foundations, private sector actors and NGOs around the world have been publishing their programme data to IATI.

IATI allows publishers to exclude certain information from their data, as long as the criteria for excluding data from publication are done in accordance with an accessible policy. The requirement from IATI stipulates that the policy of how those exclusions are made is public, to provide context to those who are using the data. Save the Children Netherlands is committed to publishing programme information each quarter in compliance with the IATI standard. SCNL publishes IATI activity files in line with the IATI standard publication frequency of quarterly publication of activity files and yearly publication of organization files. Each quarter only information readily available via existing reporting commitments will be published. Save the Children Netherlands is transparent about the exclusion policy that SCNL applies. This policy will therefore be published to the SCNL website (https://www.savethechildren.nl/), our IATI organization file and to the internal quality management handbook.

Full details of the aims and formation of IATI can be found at the IATI website (www.iatistandard.org).

 

3. General principles for exclusion

Project information can be excluded at any of the following levels:

1. a)  Entire projects or programmes (defined as “activities” in IATI)
2. b)  Project components (e.g. programmatic) within an IATI activity
3. c)  Specific data within an IATI activity (a specific “element” in the IATI standard)

4. Exclusion criteria

Project information is excluded from publication to IATI if it falls in one of the following categories:

 Child Protection

• Save the Children Netherlands will not publish information that would expose children, or their parents, families and communities to potential abuse or exploitation, such as personal information regarding assisted children.

Safety and Security

• Save the Children Netherlands does not publish data of which it can reasonably be expected that it might pose a risk to the safety or security of any individual, local Save the Children offices, groups of beneficiaries, partner organisations, (back) donors or suppliers. Therefore, detailed specific information affecting the safety and security of NGO staff, partner staff or beneficiaries will be excluded.

Operational harm

• Save the Children Netherlands may exclude any information that may harm our work or hinder our ability to operate in certain locations. Save the Children Netherlands will not disclose information if it considers that the disclosure could harm its work, whether in the Netherlands or in its international operations. For example, SCNL may exclude any politically or culturally sensitive information that may hinder our ability to operate in certain locations.

External relations

• Save the Children Netherlands does not publish data that might harm the relationship with local governments or local institutions of Save the Children Association, its partners or (back) donors. All partner organisations and back donors are informed about Save the Children Netherlands policies for publishing project data and have a possibility to request exclusion, based on the principles detailed in this exclusion policy. Save the Children Netherlands is, at all times, the final decision-maker for exclusion of data.

Privacy, data protection and confidentiality

• Save the Children Netherlands does not publish any project information (including photos, names, personal information, meta data) that is traceable to an individual person and can reasonably be judged as an invasion of the privacy of that person without prior permission of the person involved. Therefore, specific personal information of individual staff and/or partners (e.g. addresses) will be excluded.

This policy is subject to Dutch and European Union data protection and privacy legislation. Accordingly, Save the Children Netherlands will not disclose data about living individuals where this is prohibited under applicable law.

Commercial/Strategic information

• Save the Children does not publish data that might harm the commercial or strategic interests of Save the Children Netherlands, its partners, (back) donors or suppliers, if the information is not publicly available otherwise. Information about the conditions and repayments of loans, investments and guarantees is part of this exclusion and will therefore not be published by Save the Children Netherlands. For this reason, for example, financial data is only published cumulatively on a quarterly basis.

Legal/Contractual reasons

• Save the Children Netherlands does not publish data if we do not have the right to publish the data. For example, if third parties have a copyright on certain information or if contractual agreements with back donors or partner organisations impede Save the Children Netherlands right to publish the data.
• Save the Children Netherlands does not publish information that is exempt under data protection laws or by pre-existing organisational policies.

Data Quality

• Save the Children Netherlands values the quality and consistency of its open data. Therefore, Save the Children Netherlands publishes only project data that meet the minimum requirements (to be developed). Data that does not meet the minimum requirements will be excluded.

Cost effectiveness

• Save the Children Netherlands does not publish data if the costs for publishing/obtaining the data are disproportionally high in relation to the relevance of the data for the public. Save the Children Netherlands publishes to IATI on a quarterly basis information which is available as per requirements in other reporting streams. Save the Children Netherlands does not obtain additional project information per quarter solely for IATI publication purposes.

5. Decision-making on excluding data

Excluding data from IATI is done in accordance with the open data policy on the basis of the principles described above. The responsibility for checking when excluding information is appropriate lies at the level where the information can be assessed in detail, at the level of the Programme Managers. It is the responsibility of the SCNL Programme Manager in charge of the programme requiring publication in IATI to inform the relevant Save the Children International (SCI) Country Office of IATI, this policy, and our responsibility to report programme data to the IATI standard. Together the SCNL and SCI Programme Managers are responsible for checking whether one or more of the above principles applies in each individual case. Following their proposal, the Head of Save the Children Netherlands Programme Department would have the ultimate authority to decide on exclusion from the data set, based on the exclusion criteria listed above. Exclusions that entail any deviation from the IATI standard require approval from the Head of Save the Children Netherlands Programme Department. Slight adjustments to programme information, such as replacing specific information with less specific information, is done at the discretion of the Programme Manager. The IATI focal point and other relevant staff will assist the programme managers in deciding on exclusions.

 

6. Review of exclusion policy and quality of data

On an annual basis the Save the Children Netherlands IATI focal point will review whether the exclusion policy is still valid and does not unreasonably restrict disclosure of data. The exclusion policy will be reviewed and if necessary adjusted on an annual basis in the framework of the ISO certification process.

April 2019